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The Official Town Council and Planning Group of Tierrasanta
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For PDF printable image of this cover letter click HERE.
For PDF printable and searchable version of this report click HERE.
Traffic Impacts
The Draft Environmental Impact Statement (DEIS) assumes six trips per day per household from the proposed Military Family Housing Project (Site 8A or 8B), for a total of 9600 additional vehicle trips in or near Tierrasanta/Murphy Canyon. Forty percent of those trips are expected to be work-related and 60% non-work. Of the work-related trips, 15% would be Miramar-bound, the remainder toward other military base destinations. Of the 60% non-work trips, the majority (75%) would be within Tierrasanta/Murphy Canyon. Suggested mitigative measures include widening Santo Road, adding a right-turn (West-bound) lane at the intersection of Santo Road and Tierrasanta Blvd., and installing traffic signals at both ends of the Santo Road/State Route 52 (SR52) overpass.
Comment: The projected trip numbers appear to be low. They do not take into account any trips by non-residents into the project. Nor do the numbers include non-military related employment by military spouses or other dependents.
Trip number projections are further complicated by the possible commercial development of a portion of one of the on-base school sites. The San Diego Unified School District (SDUSD) is currently in discussions with a developer for the potential construction of a shopping center on a portion of the school site, lying between Site 8A and the Santo Road/SR52 intersection. Assuming those negotiations prove fruitful and the site is commercially developed, the center is likely to attract non-military customers onto the site. Those trip numbers need to be taken into account.
The school site is 58 acres, and
the proposed 8A access road uses 35 of those acres for its construction. What
happens to the rest of that land? Can it be zoned for other
commercial/industrial uses or for residential uses? Who would have oversight for development of the school site – the City of San Diego? The Draft EIS should include information about the potential impacts that such a development would have on area traffic, air operations, base security, etc.
The drafters of the Draft EIS have assumed that all work-related trips and 25% of non-work related trips would generate additional traffic onto SR52. This assumption is flawed. SR52 is already overcrowded during the morning and afternoon commutes. It is unlikely that the majority of new housing site commuters would attempt to access that route when the less-heavily trafficked Santo Road beckons in front of them. It seems probable that a significant proportion of Site 8 commuters would instead choose Santo Road and Clairemont Mesa Blvd. or Tierrasanta Blvd. as highway connectors. Those additional Tierrasanta/Murphy Canyon trip numbers need to be taken into account and mitigated.
Some proposed traffic mitigation measures are not workable. Others are inadequate. In mitigation for traffic impacts on Santo Road, the Draft EIS proposes widening of a portion of Santo Road. This widening is not desirable to the community, as it would require either the elimination of existing sidewalks and/or center islands or the encroachment upon and acquisition of private property. Additionally, the Draft EIS proposes installation of a West-bound turn lane off Santo Road onto Tierrasanta Blvd. to accommodate the AM commute, but does not address modifications likely needed to the North-bound turn lane off Tierrasanta onto Santo to accommodate the PM commute. Likewise, similar measures should be considered for the Santo/Clairemont Mesa and Santo/Aero Drive intersections.
The Draft EIS does not address public or private mass-transit options either on base between the East Miramar housing site and the West side facilities (commissary, exchange, movie theatre, medical clinic, etc) or off base between East Miramar (Site 8) and Tierrasanta/Murphy Canyon. Jitney or bus service has the potential to significantly reduce traffic volumes and should be considered.
The DEIS ignores the obvious safety concerns inherent in having only one entrance/exit to and from Site 8. Multiple traffic approaches are essential to ensuring escape routes in case of fire, aircraft incident, earthquake or other catastrophe. An internal East-to-West Miramar road would provide that safety measure while also mitigating traffic impacts to SR52 and the Tierrasanta/Murphy Canyon community. It would also improve quality of life for Site 8 residents by easing access to base facilities.
At least two roads are required for access to Site 8 in order to provide for public safety (in case one road is made impassable) and in order to mitigate the impact of Site 8 traffic on the neighboring community of Tierrasanta/Murphy Canyon. Recommendation: The TCC recommends the following access road plan, in order of preference:
1st: the new SR52 interchange (for the Site 8B alternative) plus a new access road internal to MCAS Miramar that connects Site 8 directly to Miramar Way (or to Kearny Villa Road, or to I-15).
2nd: the Santo Road extension (for the 8A alternative) plus a new access road internal to MCAS Miramar that connects Site 8 directly to Miramar Way (or to Kearny Villa Road, or to I-15).
3rd: the Santo Road extension plus the new SR52 interchange (both the 8A and 8B alternatives).
4th: the new SR52 interchange (Site 8B alternative) alone; this option is considered not acceptable from the perspective of public safety.
5th: the Santo Road extension (Site 8A alternative) alone; this option is considered not acceptable from the perspective of public safety and due to the impact this would have on the Tierrasanta/Murphy Canyon.
Recommendation: The Tierrasanta Community Council strongly recommends the Final EIS include an internal East-to-West Miramar connection, possibly accessing Miramar Way. An internal base corridor would very substantially reduce community impacts, improve safety and quality of life for housing residents, and do so at a cost at or near that of the off base traffic mitigation measures otherwise required.
School Impacts
The Draft EIS identifies current student enrollment and available expansion capacity in Tierrasanta/Murphy Canyon schools. It also projects the numbers of elementary, middle, and high school students expected to be added to the system and concludes that local schools have adequate available capacity to accommodate the increase in attendance. Nevertheless, the Draft EIS identifies land set aside within Site 8 for up to two elementary schools. No federal funding is available for school construction. The San Diego Unified School District would be expected to fund any new construction.
Comment: Tierrasanta/Murphy Canyon schools are already over-crowded. Tierrasanta/Murphy Canyon schools were under-sized when constructed and have only kept pace with community expansion by the addition of bungalows at each school site. All schools within the community have bungalows. The number of bungalows ranges from a low of nine at Tierrasanta Elementary to a high of 24 at Serra High School. The infusion of a projected 1172 elementary school students, 228 middle school students, and 163 high school students would mean a concomitant increase in the numbers of temporary classroom facilities. More bungalows added to already crowded school sites would mean smaller playgrounds, likely infringing upon play areas the community is turfing under a City/School District Joint Use Agreement at a cost exceeding $1.5 million. The addition of 1563 new students to the system would severely stress lunch and library facilities, playgrounds, and gyms. These impacts must be mitigated. Appropriate mitigation should include federal funding for concurrent construction of the proposed elementary schools within the Military Family Housing Project.
The Navy’s projections for numbers of new students should be re-examined. The numbers are significantly lower than actual student generation rates for the Murphy Canyon Military Family Housing Project. The Draft EIS projects .977 students per household for the new housing project while Murphy Canyon actually generates 1.427 students per housing unit. If the Murphy Canyon rates are representative of what can be expected from site 8, that would mean 2,283 new students not 1563.
School enrollment and capacity numbers should also be adjusted to reflect full occupation of Murphy Canyon Military Family Housing. The Navy has been renovating Murphy Canyon Military Family Housing Project for the past five or six years. This ongoing renovation has resulted in lower occupation rates; that is, empty units. Any projection of expected student populations for Tierrasanta/Murphy Canyon schools should include the numbers of students to be generated from a complete and fully utilized Murphy Canyon, as well as a built-out Site 8.
Page 3.4-2 of Vol. I states, “The existing elementary schools in the surrounding communities of the proposed housing development for Site 8 include Vista Grande, Kumeyaay and Tierrasanta.” Why is the Draft EIS “silent” on using Hancock or Miller Elementary Schools in the Tierrasanta/Murphy Canyon community? Is there a reason why the two elementary schools located within the existing Murphy Canyon Military Family Housing area are not being considered for housing Site 8 elementary aged students should the proposed two elementary schools in the project site not be built in a timely manner by the San Diego Unified School District?
The anticipated school population
for 2003-2004 at De Portola Middle School is 1035 students and will require 2
separate lunches to attempt to accommodate the students. Staff on site believe
that they will not be able to process all the students through the 2 lunch
periods in the time allocated. If bungalows are brought on campus, then the
school can accommodate 1080 students.
Recommendation: The Tierrasanta Community Council strongly recommends the Final EIS include federal funding for concurrent construction of two elementary schools within the housing footprint. Concurrent construction would virtually eliminate impacts on community schools while significantly reducing impacts on traffic, parks and recreation, and the community library.
Park and Recreation Impacts
The DEIS does not adequately address park and recreation impacts.
Comment: While the Draft EIS lists proposed playgrounds, tennis courts, volleyball, and basketball areas, it does not address size or capacity of those facilities, planned recreational programs, or, most critically, the availability of funding for construction of any recreational facilities. The Tierrasanta/Murphy Canyon community can expect its recreational facilities and programs to be substantially impacted by construction of an additional Military Family Housing Project, which does not include adequate recreational outlets for its residents. During the scoping process and public meetings held in September and October of 1999, impacts to parks and recreation facilities were among the issues most frequently raised by the Tierrasanta/Murphy Canyon community.
The City of San Diego guidelines for parkland in housing developments call for 2.8 acres of parkland for every 1000 persons. The proposed Military Family Housing Project should at least meet that guideline. This is a citywide guideline applicable to a typical housing development which would consist of units with children, and units where no children would reside. As noted in the San Diego Union-Tribune of article April 30, 2001, the census tract that includes Murphy Canyon military housing has a large number of youth per household with 54% of the residents 17 years old or younger. The Tierrasanta Community Council suggests appropriate mitigation would include adequate parkland to serve both the new project and the existing Murphy Canyon Heights Military Family Housing Project, which is woefully underserved. Murphy Canyon, which currently houses approximately 10,000 residents, has only 8 to 10 acres of parkland, approximately one-third of what it would need to meet City guidelines. . The Final EIS needs to include: - An analysis of the impacts to Tierrasanta Recreation Center programs, parks, playing fields, indoor gymnasium and pool, and the existing Murphy Canyon recreation center facilities from the proposed military family housing including mitigations. - An analysis of park and recreation needs of both Murphy Canyon and the proposed housing to alleviate the inadequate recreation facilities for military families in both communities.
Will Site 8 residents be allowed to use Murphy Canyon playing fields and recreation facilities?
Recommendation: To ensure a high quality of life for residents of the proposed Military Family Housing Project and to reduce impacts on Tierrasanta/Murphy Canyon, the Tierrasanta Community Council strongly recommends the Final EIS include concurrent construction of a gymnasium, a swimming pool, a skateboard park, outdoor basketball courts, and sufficient parkland and turfed fields to accommodate soccer, football, softball, and Little League activities for Site 8 and Murphy Canyon. We note the existing tennis courts at Murphy Canyon are under-used. Therefore, the construction of new tennis courts at Site 8 is not recommended.
Library Impacts
Comment: The DEIS does not address impacts to the Tierrasanta Library. The construction of 1600 housing units at Site 8 and the accompanying addition of 1563+ students into the area will have a significant impact on the Tierrasanta Library. The current library, serving Tierrasanta/Murphy Canyon, was constructed in 1984. It is an 8,766 square foot structure with 24 adjacent parking spaces. The City of San Diego’s current standard for new library construction calls for a structure with a minimum footprint of 15,000 square feet. The existing structure is nearly 50% below that standard and is full to capacity on nearly any given day.
Recommendation: The Final EIS should address mitigation efforts to curtail library over-crowding. Appropriate mitigation might include construction of a new library facility. Alternatively, the concurrent construction of two elementary schools within the housing project footprint and with appropriate on-site library facilities for use by students and the community would reduce or eliminate the need for off-site library mitigation efforts.
Environmental and Biological Impacts
The DEIS suggests that environmental impacts on endangered species and wildlife will be insignificant.
Comment: The DEIS states that large mammals have unfettered access from East Miramar to Mission Trails Regional Park (MTRP) via a SR52 underpass. Deer, coyotes, and other large mammals have relied in the past on a tunnel under SR52, created expressly for their use, to move from one feeding or watering area to another. However, base officials have blocked this access route, apparently in an effort to keep mountain bikers out of East Miramar. The lack of access into and out of MTRP impacts the wildlife populations. Though Site 8 technically does not contain a linkage, the linkage cited is not viable any longer for all mammals in the area and the document needs revision and the implication of said blockage needs review.
The description of the wildlife linkages between the areas north and east of the proposed Site 8, and the connections to the "wildlife under-crossing beneath SR 52" needs to be more clearly addressed in the Final EIS as well as in the Biological Resources Technical Report.
Specifically, the location of the under-crossing needs to be mapped to show the proximity and potential impact on its use by wildlife (in both the Final EIS and the Biological Resources Technical Report).
The wildlife using the under-crossing need to be clarified in order to determine the potential impact of the proposed housing development on the use of this corridor.
Page 97 of Vol. II (Biological Technical Report) states that the Site 8A proposed project directly impacts the habitat linkage to East Miramar, East Elliott open space area, and Mission Trails Regional Park, by restricting the movement of large mammals such as mule deer and coyotes, but then states that the impact is not significant because there is lots of other land available on the base to accommodate the needs of those species. Page 98 of Vol. II presupposes that the majority of wildlife movement in the area takes place in the “unaffected” Oak, Spring and Sycamore Canyons. The Draft EIS fails to look at the cumulative impacts of other proposed development in the region (Rancho Encantada, Sycamore Landfill expansion, East Elliott development, and intense uses of the land by Marines for training that have not yet been identified).
The Navy has consistently told members of the Tierrasanta Community Council that there is no intention to construct a security gate leading from the proposed military family housing back into the base. The general public will have full access to the proposed housing area from the Santo Road/SR52 interchange. The general public will have full access to the proposed military family housing area. The only “security” will be an 8-foot fence constructed around the perimeter of the housing area. It is not clear whether an 8-foot fence will also be constructed along the access road leading from the intersection. A simple solution to the wildlife movement issue is to reopen the SR52 underpass, since it is apparent that in siting military family housing in this area of the base, that security is not an issue. If that is the case, the SR52 underpass should be reopened. If it is not reopened due to security reasons, then the Navy should reconsider its decision to allow the general public full access to the Santo Road extension north of the SR52 intersection.
Recommendation: A more comprehensive environmental analysis must be done
on the impacts of the proposed project. The tunnel must be reopened or the
rationale for keeping it closed explained in depth. Comment: Numerous endangered or threatened species would be impacted by development and occupation of Site 8. They include gnatcatchers, Hermes copper butterfly, Chamise chaparral, and summer holly. The DEIS does not adequately explain how mitigation of species habitat losses would be accomplished.
In a previous study, gnatcatchers were noted in the Site 8 area. What effect will the long-term construction (at least 3 years) of the housing project have on this species and will the habitat loss be significant in terms of Federal law? If any gnatcatchers are in the area, they will be displaced from the habitat during the period of construction. Long-term construction of this project spread over several years will significantly affect breeding.
What effect will this project have on the listed species including Hermes Copper butterfly? There is an active effort going on to get this species listed by United States Fish & Wildlife Service. The impacts from this project and other East County projects could induce a listing. How will this impact be mitigated?
Chamise chaparral is actually a difficult habitat to restore. The draft document makes no provision how this significant loss will be mitigated. All alternatives call for removal of large stands of Chamise chaparral. Chamise chaparral is much more difficult to restore than coastal sage scrub or other vegetation types. The EDAW report’s description of Chamise chaparral includes reference to a “diverse herbaceous layer in open stands” and cites several species that are sensitive or locally restricted to the coastal or mesa vegetation stands as common (Pentachaeta aurea a CNPS list 4 plant and Selaginella cinerascens a former CNPS list 4 plant). Furthermore the Coastal Commission has begun to recognize the rarity of this vegetation and has ruled on coastal stands of Chamise chaparral in the Santa Monica Mountains as environmentally sensitive habitat. How does the Navy reconcile these facts and what mitigation is offered?
Page 93 of Vol. 2 in the Biological Technical Report states that few major populations of Summer Holly are known in San Diego County, yet maintains that the mitigation for the proposed housing will reduce impacts to the species to below a level of significance. How is that possible if an area of equal size is not created elsewhere?
Recommendation: The Final EIS must address the impacts to specific species identified in the immediate project area, the proposed mitigations in detail, and the likelihood of the success of the proposed mitigations.
In addition, mitigations for many of the impacts presented in the Draft EIS are referenced as being covered by actions or mitigations in the Integrated Resources Management Plan (INRMP). For clarity these should be called out with not only a reference to the INRMP but should also include a brief "such as…" This will lead the reader, including decision makers, to understand that there really are mitigations that will be applied.
Comment: Construction at Site 8 would overlap the 2000 acre Research Natural Area (RNA). The RNA was set aside in 1987 to conserve relatively undisturbed vegetative types to provide educational opportunities and research areas for scientists to study the ecology and other aspects of the natural environment. Impacts to the RNA are not consistent with Department of Defense (DoD) Instruction 4715.3, in that the construction of military housing is not one of the “triggers” for reassessment of the land use.
When the RNA was established, there were no threatened or endangered species identified within the RNA, and the area was not required for NAS Miramar’s mission.” The document also states that, “The RNA cannot be considered a permanent preserve.” And that, “Such areas shall be reassessed if the military needs of the installation change, during any base realignment closure action involving the property, or if the property becomes excess and requires disposal,” citing DoD Instruction 4715.3, Paragraph F.1.j. Is providing military family housing on base part of the MCAS Miramar “mission?”
The quoted military instruction that allows designation of research areas of significant natural resources references a potential change in the designation of the RNA to unclassified land as justified on the basis if the military needs of the installation change, “during any base realignment closure action involving the property or if it becomes excess and requires disposal.” What base realignment or closure is being contemplated? If a base closure is being contemplated, then should federal funds be expended on a military family housing project when the base would potentially be abandoned in the near future? If a base closure or realignment is not contemplated, or the property has not been deemed to be “excess,” then the action (to re-classify RNA land) seems to be unjustified. Please quote the appropriate and complete legal justification for this action.
The document states that the RNA designation would need to be terminated. However, this property consists of protected habitat and the resulting withdrawing of the RNA designation would mean a cumulative loss of habitat. The case for insignificance is overstated. How will this loss of habitat be mitigated?
The Draft EIS says that
approximately 300 acres of the RNA would be impacted, but on page 19 of Vol. I
it clearly shows that with the inclusion of the safety zone around the housing
site, a total of 453.46 acres will be disturbed for Site 8A. While the Draft
EIS states that there will be some revegetation of the safety zone area so
that the impacts may not be “permanent,” the statement is also made that if a
perimeter fence is installed, that the impact may be to the entire area. Given
that the Marines have closed off the underpass at SR52 citing security
concerns, there is every possibility that a perimeter fence will be
constructed around the housing area.
Section 4.7. This section states that the proposed preferred alternative would have no impact to biological resources due to the fact that the action “would remove all biological resources within the project footprint.” Table 4.7-1 mentions that the loss of significant vegetation/habitat at site 8 would be approximately 32 acres, which represents 12 % of the habitat within the project APE. No clear rationale for the above determination is provided except to say it was deemed insignificant. Recommendation: The Final EIS must address the true impact of the loss of the RNA to this region, and the proposed mitigations for such loss. The Final EIS must also clearly state what the development area is, and what the total anticipated loss of species and habitat is expected to be.
Comment: The Draft EIS does not address the loss of open space at Miramar which would occur with the development of Site 8. This factor must be considered in the Final EIS and mitigated.
The Draft EIS does not address potential impacts on MTRP, nor does it offer mitigation for those impacts. On page 4.1-3 it states that site 8 is separated by SR-52. However, Mission Trails Regional Park is the nearest significant open space park. The proposed addition of about 6,304 new residents and the use of the park by the residents would be a significant effect on MTRP. No mitigation is offered. Potential adverse impacts to trails, habitats, other resources, would certainly occur from increased use. Since the military is not providing usable open space alternatives or parks, the likely impact on Mission Trails Regional Park cannot be avoided.
Recommendation: The Final EIS must indicate the impact to Mission Trails Regional Park and its pristine natural habitat by the likelihood that an additional immediately adjacent community of more than 6300 people will have on the regional park. The Final EIS should indicate what possible mitigation efforts could minimize the impact.
Comment: The Draft EIS should address off-site as well as on-site impacts on local flora and fauna. Page 76 of Vol. II states that off-site indirect impacts of the project include: outdoor night time lighting, increased noise, increased urban runoff, the potential for invasion of exotic species into the native plant communities, and interference with wildlife movement. On page 115 of Vol. II, it states that lighting and noise impacts to gnatcatchers in areas adjacent to the development area are anticipated. The Navy should be held to the same standard that a private developer would be held for impacts like these to local flora and fauna. It is our understanding that private developers are required to meet the Regional Water Quality Control Board standards regarding impacts to stormwater runoff, etc. To what environmental standards will this Public/Private Venture be held?
Recommendation: The Final EIS must clearly define to which environmental protection standards the Public/Private Venture will be held, and what agencies will be overseeing the project during its construction and operating phases.
Comment: The Draft EIS gives short shrift to any discussion of unexploded ordnance, putting off any real consideration of impacts or mitigation until the CERCLA process is underway. This constitutes unacceptable splitting or segmentation of projects. More importantly, Site 8 lies within the impact zone of military artillery practice on old Camp Elliott. Therefore, there is a substantial likelihood of the presence of unexploded ordnance within the housing project footprint.
On page 4.7-2 the Draft EIS briefly discusses potential impacts due to Unexploded Ordnance (UXO) removal activities. The discussion puts off additional discussion of impacts and mitigations until the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) response is under way. This approach to addressing the potential impacts and mitigations due to CERCLA actions is not appropriate. Since the CERCLA actions are directly related to the implementation of the military family housing project, to split off discussion of the impacts and the mitigations to be implemented is segmentation of the projects. Segmentation of the military family
housing project impacts and mitigations from the CERCLA response impacts and
mitigations is not in compliance with NEPA requirements, because these impacts
are not really unknown. There is extensive experience and information
available from the UXO clearance program in Tierrasanta, which could be used
to clarify the potential impacts for the public and the Decision Makers. Recommendation: A more detailed discussion of the expected impacts and the mitigations (at least representative if not expected and committed to) to be implemented should be included in the Final EIS. Cost and safety factors must be explored. A full discussion must be presented in the Final EIS.
Comment:
The Draft EIS does not discuss the cumulative impacts of multiple development
projects in the area including the proposed siting of 498 homes in the East
Elliott area by Pardee Homes (Castlerock project), and the proposed expansion
of the Sycamore Landfill. For example, on page 2-6 of Vol. I it states that
the East Elliott area will become parkland and does not address the proposed
civilian housing.
Recommendation: The Final EIS should include impacts and mitigation measures, taking into account Site 8, the Pardee Homes Castlerock Project (488 homes in East Elliott), and the proposed expansion of the Sycamore Canyon Landfill. Comment: The DEIS does not address the real possibility that Site 8 will be only the first phase of a three-phase housing construction project in East Miramar.
Recommendation: Since it appears likely, based on the Navy’s reports of the military housing shortfall in the San Diego area, that additional housing units will be required after completion of Site 8 and, since the Navy apparently believes no adequate housing sites are available to it outside of East Miramar, any further development will necessarily take place in that location. The Final EIS should, therefore, consider impacts and mitigation measures for all potential military housing sites in East Miramar.
Comment: There are four identified cultural resources listed in the Site 8 alternative. Often the sub-surface component of archeological sites is not clearly evident from surface investigations. Prudent archeological practice indicates in said investigation, sub-surface testing is warranted to determine if potential eligibility is indicated or not. Surface reconnaissance should not alone be used to evaluate cultural resources. It seems that some sub-surface investigations are warranted.
It also seems unlikely that an historic camp with a trash dump, including a deflated gun pit, could not be relocated or was completely destroyed by minimal road construction and grading. Was sub-surface testing applied in this case? If it relates to Camp Kearny, potentially it could be eligible for the National Register.
Recommendation: Conduct sub-surface investigations of the four identified cultural resources identified in the Site 8 alternative.
Public Safety
Will there be full paramedic staff at that station? If so, will it be staffed with certified paramedics 7 days a week, 24 hours a day? If not, will Tierrasanta Fire Station 39 be responsible for providing paramedic service to the 1600 households at Site 8? Will the City of San Diego receive reimbursement for paramedic service provided “on base” to military families?
How will serving the new military family housing impact the paramedic response times for the Tierrasanta/Murphy Canyon community?
Will a “brush rig” be stationed at the proposed federal fire station within Site 8 on a full time (7 days a week, 24 hours a day) basis? The Tierrasanta/Murphy Canyon, East Miramar and Mission Trails Regional Park area is subject to brush fires and having adequate firefighting equipment on site is essential to protect life and property.
Recommendation: The Final EIS should be more explicit in terms of what public safety services will be provided at the proposed federal fire station, including paramedics and a brush rig.
Comment: While the
Draft EIS is clear that this project will be a public/private venture, nowhere
in the Draft EIS does it clarify which entity is responsible for paying for
what during the development phase – except for the schools, when the Draft EIS
states that the Navy will provide the land for 2 elementary schools on site,
but that it is the responsibility of San Diego Unified School District to
construct and operate the schools. What will
the Department of Defense/Department of the Navy be responsible for
constructing and what exactly will be included in the RFP/RFQ as the
developer’s responsibility? term lease to a private developer, what will be the role of the Shore Patrol or Military Police in the housing area? Will the private developer provide private security for the site?
Recommendation: The Final EIS should clearly state what each party to the Public Private Venture for the Military Family Housing project in East Miramar will be responsible for constructing and maintaining over the 50 year lease agreement. Comment: The Draft EIS is deficient in that it does not show on a single map where the publicly and privately held lands in the area are located.
Recommendation: Create a map showing Site 8A and 8B and Rancho Encantada; East Elliott area that is zoned residential, etc.; Mission Trails Regional Park; school sites; any other lands north of State Route 52 that are not part of MCAS Miramar.
Determination of Significance
Comment: The Tierrasanta Community Council suggests that a section be added describing the methodology, or thresholds used to determine the significance of biological, as well as other impacts, caused by the proposed project. We have attached two documents that suggest methods for determining significance.
Recommendation: Include a section detailing the methodology or thresholds used to determine the significance of biological and other impacts caused by the proposed project.
Impacts to Tierrasanta Postal Store
Comment: The Tierrasanta/Murphy Canyon community is currently served by the Tierrasanta Postal Store, not a Post Office, which is significantly impacted already by the large number of customers utilizing its services. At times, patrons are lined up out the front door of the facility.
Recommendation: The addition of 1600 new homes in the immediate vicinity of the Tierrasanta Postal Store, which is located right at the intersection of State Route 52 and Santo Road, will be significant, and should be addressed in the Final EIS. Possible mitigations include siting a Post Office in the Tierrasanta/Murphy Canyon community, or siting a Postal Store in the mini-mart planned for Site 8.
Comment: On page 4.4-2, it states that, “The nearest police station to Site 8 is the City of San Diego Eastern Division, located at Aero Drive in the community of Tierrasanta, located approximately 5 miles (8 kilometers) from Site 8.” The Eastern Division Police Station is located in the Serra Mesa community. Recommendation: Correct the Final EIS as noted above. Traffic AnalysisComment: Page 30, Table 4.1 “Military Housing Sites Project Trip Generation – Source: 1996 Military Housing Trip Generation Study; URS/BRW, Inc.” – Since then, NAS Miramar became MCAS Miramar, and the trip generations may have significantly changed as the base use changed. Recommendation: The Draft EIS is incomplete in its traffic analysis impacts and a true assessment of the existing conditions has not been determined because there may be differences in traffic patterns between a Naval Air Station and a Marine Corps Air Station. The Final EIS should include accurate numbers. Comment: Page 44 – the Rancho Encantada project will have 566 single family homes and 106 multifamily units, for a total of 672 units, plus 12 acres for schools, 4 acres for parks and 12 acres for churches. Yet the Rancho Encantada project is expected to generate 10,548 daily trips, of which 9500 will have origins or destinations outside the project site, with the remainder inside the project area. The military family housing project will construct 656 townhomes and 944 apartments. Why is there such a difference with the 1600 proposed military family units in terms of trips generated, which according to the Draft EIS are only supposed to generate 9600 trips per day? Recommendation: Explain the rationale used that determined that fewer units in the Rancho Encantada housing area will generate more trips per day than Site 8, which will have more than twice the number of homes. Cost Analysis Comment: Additional analysis should be conducted on the cost of constructing an interchange to specifically serve the proposed military family housing project when factoring in the extraordinary costs required to conduct the cleanup of unexploded ordnance along the 2-1/2 mile access road, the potential widening of both Santo Road and Tierrasanta Blvd., and the possible widening of the Santo Road bridge, etc. The Final EIS should also research whether a new interchange could also accommodate development at Pardee Homes’ proposed development in East Elliott. Recommendation: Conduct a detailed cost analysis of the construction of a new interchange versus expanding Santo Road and Tierrasanta Blvd. and expanding the Santo Road Bridge, plus the cost required to clear the 2+ mile access road from Santo Road to the military family housing site.
Specific Comments regarding Traffic Analysis: Traffic Issue 1: Widening of Santo Road north of Portobello Road. The Draft EIS reports that Santo Road, from Portobello Drive to Clairemont Mesa Blvd., needs to be widened from four lanes to six lanes in order to support the planned traffic volume. It also reports that the intersections along this part of Santo Road will operate at acceptable Levels of Service (LOS) even without the recommended widening. This confusing wording suggests a possibility that this mitigation (and perhaps all other mitigations contained in the Draft EIS) are discretionary and thus subject to later review, possibly without involvement of the affected community.
Traffic Comment 1: The Final EIS should clarify whether the planned mitigation includes widening the northern section of Santo Road, or whether the plan is NOT to widen this section of Santo Road.
Traffic Issue 2: Obtaining Land for Road Widening. Given the response to the above comment is that the northern section of Santo Road should be widened, the Tierrasanta Community Council (TCC) wonders how will this be achieved when the act of widening the road would involve acquiring what appears to be the privately owned property of adjacent homeowners?
Traffic Comment 2: The Final EIS should state whether funding will be provided to obtain rights of way from current landowners for the purpose of adding additional traffic lanes (while maintaining the other existing infrastructure such as bike lanes, sidewalks, the existing center island, etc.).
Traffic Issue 3: Commuter Use of Surface Streets. The Traffic Analysis in the Draft EIS wrongly assumes that 100% of work-related travel will involve the use of SR52 and I-15 when traveling between Site 8 and MCAS Miramar, and it assumes 0% of the work-related travel will bypass the I-15/SR52 intersection and instead take surface streets. As an example, the Draft EIS completely fails to address the likely scenario that afternoon traffic departing MCAS Miramar and bound for Site 8 would be very likely to avoid the LOS E or F traffic on eastbound SR52 (this is reported nearly every evening on the local media traffic reports) and instead elect to use surface streets (the well-known “work around” route often used to bypass eastbound SR52 congestion is: Kearny Villa Road south to Clairemont Mesa Blvd. westbound to Santo Road northbound).
Similarly, the Draft EIS reports that fully 85% of commuter traffic from Site 8 will be heading for military stations other than MCAS Miramar. Once again, the Traffic Analysis in the Draft EIS incorrectly assumes that 100% of work-related travel will use SR52 and I-15 when traveling between Site 8 and the military stations south of MCAS Miramar, and it assumes 0% of the work-related travel will bypass the I-15/SR52 intersection and instead take surface streets. The common freeway bypasses for commuters heading to destinations south of MCAS Miramar include Santo Road south to Tierrasanta Blvd. (or to Aero Drive), and from there either to enter I-15 further (south of the SR52 interchange) or to continue westward along Balboa Avenue (or Aero Drive) to SR163. The Draft EIS completely fails to address the impact to Tierrasanta roads by commuters that bypass the frequently clogged freeways and freeway interchanges.
Traffic Comment 3: The TCC believes that the Draft EIS’ proposed mitigations were based on a significantly flawed analysis, and this calls into question the entire validity of the traffic mitigation plan. For instance, it would seem clear that mitigation is probably required to expand left-turn lane capacity from Tierrasanta Blvd. eastbound to Santo Road northbound (to accommodate the afternoon rush hour and the additional traffic caused by Site 8 personnel heading home from military stations to the south), yet the Draft EIS neither recognizes the need for such mitigation nor does it predict any measurable impact to this intersection’s traffic flow.
The Traffic Analysis of the Final EIS should be reworked in toto to address the completely predictable scenario of commuters bypassing poor-LOS freeways and instead using surface streets. This reworked analysis is required because every surface street bypass heading from Site 8 starts on Tierrasanta roads (in the AM commute), and every surface street bypass heading to Site 8 ends on Tierrasanta roads (in the PM commute). This analysis must be reworked because the impact from such commuters will directly affect virtually all of the proposed mitigation sites, including Santo Road south of Portobello Road and the intersection of Tierrasanta Blvd. and Santo Road.
The Traffic Analysis should accurately reflect the fact that SR52 is only 2 lanes in each direction from I-15 east to Santee.
The Traffic Analysis should accurately reflect the fact that Tierrasanta Blvd. from I-15 to its terminus in Tierrasanta is only 2 lanes in each direction, except for turn lanes onto Santo Road and La Cuenta Drive.
Traffic Issue 4: Santo Road Bridge over SR52. The Draft EIS does not predict a need to widen or otherwise improve the existing Santo Road overpass at SR52, even though the current bridge design accommodates only two traffic lanes and a bike lane. Restriping might permit adding a left turn lane, but this would probably eliminate the bike lane and it would make the addition of a walking path (sidewalk) impossible. As noted above, the mitigation plan appears to suggest a need to widen Santo Road south of the bridge (from Portobello Road to Clairemont Mesa Blvd.) from four lanes to six lanes, but what sense does this make if the bridge itself only supports two or three lanes of traffic? Given the Site 8A alternative, where all 9,600 trips per day must enter the Santo Road interchange with SR52 and where a large portion of these must cross over the bridge, the traffic analysis appears to have missed the mark in assessing a need to address the lane capacity of the Santo Road bridge.
Traffic Comment 4: The Final EIS should revisit the adequacy of the Santo Road bridge over SR52. A reworked Traffic Analysis should address commuters’ use of surface streets (as noted above) and, in this context, it should reevaluate the need to expand and otherwise improve the Santo Road bridge. Improvements that should be considered are: maintaining the existing bike path, adding a sidewalk, and accommodations for the various utilities (water, sewer, power, natural gas, cable TV).
In addition, if the bridge must be widened to accommodate the addition of utility pipes, etc., then the Navy should be required to resurface both the bridge and the length of Santo Road to where the new utility lines connect.
Traffic Issue 5: Use of Incorrect Traffic Predictions. The numbers presented in Appendix C of the Draft EIS predict an explosion of traffic along Tierrasanta Blvd. in the 2020 timeframe. The Draft EIS also predicts Site 8 housing will measurably worsen this condition, and as such it proposes improvements to the intersection of Santo Road and Tierrasanta Blvd. in order to accommodate a predicted LOS E or F level of traffic along Tierrasanta Blvd. in the 2020 timeframe.
Liaison on 22 July 2003 with Mark Peterson of URS, a listed contributor to the Draft EIS (in Chapter 8 of the report), determined that the related traffic analysis most probably involved the use of mistaken traffic predictions that assume Tierrasanta Blvd. will be extended across the San Diego River to Princess View. It was explained to Mr. Peterson that this extension had been removed from the SANDAG 2030 Regional Transportation Plan, and that community efforts would continue to have this extension removed from all related community plans. He agreed that the traffic analysis numbers resulting from the assumption that Tierrasanta Blvd. connecting to Princess View would be significantly different from numbers resulting from the assumption that these roads would not be connected, and he concurred that the resultant mitigation plan also might be impacted. Specifically, if traffic levels in 2020 do not double from what they are today (as the analysis predicts), then the need to provide mitigations to Tierrasanta Blvd, and the detailed plans for same, might well require wholesale revision.
Traffic Comment 5: The traffic analysis of the Final EIS should be reworked to update the predicted volume of traffic passing through the intersection of Santo Road and Tierrasanta Blvd.
Traffic Issue 6: Ramification from the Use of Incorrect Traffic Predictions. Assuming the analysis is mistaken and a total rework is required (as described above), it then would appear the only likely reason traffic volumes along Tierrasanta Blvd. could increase significantly would be due to the impact of traffic related to the Site 8 residents. This is because the community of Tierrasanta/Murphy Canyon is effectively “built out” such that few if any new homes can be built, no significant influx of new residents can be expected, and thus no doubling of traffic volume may reasonably be anticipated.
The Draft EIS documents how the additional traffic impact from Site 8 will be of sufficient magnitude (causing a measurable degradation to LOS) to warrant a rework of the eastbound and westbound approaches to intersection of Tierrasanta Blvd. and Santo Road. This impact was deemed significant in the context of an explosion of traffic by 2020 (from the mistaken assumption that Tierrasanta Blvd. would be connected to Princess View). It therefore can be assumed that in the absence of an explosion in traffic in 2020 (given the more likely correct assumption that Tierrasanta Blvd will NOT be connected to Princess View in the Mission Gorge area), the impact due to Site 8 traffic would still remain, but its proportional effect on this intersection would be much greater. This follows from an assumption that Site 8-related traffic is largely independent from non-Site 8 traffic on Tierrasanta Blvd.: if the predicted volume of non-Site 8 traffic does not double (the Draft EIS mistakenly predicts it would) then a fixed “delta” caused by Site 8 would have roughly double the impact or significance.
It is difficult to assess whether mitigation at the intersection of Tierrasanta Blvd. and Santo Road would be required in the absence of the Tierrasanta Blvd. extension. This is because the impact from Site 8 traffic would be proportionally larger and thus have a greater relative impact (which the Draft EIS fails to address), but the aggregate levels of traffic along Tierrasanta Blvd. would be significantly lower (than the Draft EIS predicts). A rework of the Traffic Analysis is required in order to more accurately resolve what may be expected and what should be mitigated.
Traffic Comment 6: The TCC believes the Tierrasanta Blvd. analysis to be fatally flawed for the reasons stated above. The analysis needs a complete rework given a corrected assumption regarding Tierrasanta Blvd. through traffic (and, from above, given a better prediction of Site 8 commuter traffic that frequently will bypass the nearby sections of SR52 and I-15). This rework is required in order to revalidate whether (and when) mitigation of the Tierrasanta Blvd. and Santo Road intersection is needed.
But assuming the mitigation remains required, the TCC wonders how will this be achieved when the act of widening the road would involve acquiring what appears to be privately owned property of the adjacent Villa Portofino homeowners (on the north side of Tierrasanta Blvd.)? If the mitigation remains a requirement, the Final EIS should state whether funding will be provided to obtain rights of way from current Villa Portofino landowners for the purpose of adding additional traffic lanes (while maintaining the other existing infrastructure such as bike lanes, sidewalks, the existing center island, etc.). Traffic Issue 7: An Alternate Proposal for Traffic Mitigation. As stated above, the Draft EIS’ failure to address the common practice of motorists using surface streets (to bypass freeway traffic jams) is a major and probably fatal flaw of the traffic study. The effect this has on Tierrasanta/Murphy Canyon is significant because absolutely all of the surface street access to and from Site 8 must occur via Santo Road (in the Site 8A scenario, where access to the Site is via the existing interchange at Santo Road and SR52). Any time there is a rush hour traffic tie-up somewhere near the intersection of SR52 and I-15, or any afternoon the eastbound lanes of SR52 operate at LOS E or F (which happens nearly every day), it would be perfectly normal for Site 8 commuters to avoid these freeways and instead utilize Tierrasanta/Murphy Canyon surface streets: Tierrasanta Blvd., Clairemont Mesa Blvd., Santo Road and Aero Drive.
The reason all such traffic must use Tierrasanta/Murphy Canyon surface streets is because the plan for Site 8 includes no provision whatsoever for any surface street access on the north side of SR52 (on MCAS Miramar property). This necessarily means the only possible freeway alternate is via surface streets on the south side of SR52, within Tierrasanta/Murphy Canyon. What this does is place virtually all of the Site 8 traffic on Santo Road, Clairemont Mesa Blvd., and Tierrasanta Blvd.
As noted above, the proposed mitigations that involve the widening of existing roads or adding lanes to existing roads may in fact be impossible to implement given the serious impact this action would have to the homes whose property in part would have to be acquired. In all these cases, the only plan provided in the Draft EIS is to implement mitigations south of SR52 even though these may be unachievable at worst (or very expensive at best).
Traffic Comment 7: The Final EIS should address the possibility of providing mitigation on the north side of SR52 for traffic bound to/from MCAS Miramar (or other points north): by the building a new road inside MCAS Miramar, one that would allow Site 8 traffic to bypass both the freeways and the surface streets of Tierrasanta/Murphy Canyon. Specifically, the Final EIS either should include provision for an alternate surface connection from Santo Road to Miramar Way (or to Kearny Villa Road), one that lies north of SR52, or the Final EIS should provide explanation on why such alternate mitigation is impossible.
Traffic Issue 8: Single Access Road for Site 8. From the perspective of public safety and emergency response, the TCC wonders whether the provision of a single access to and from a 1600-unit community is even permitted? What would happen if a brush fire takes hold right at the Site 8 access road? Or what if a flight accident were to occur and a plane went down right on that single access road, and then fires around Site 8 were caused by the spilled fuel? How would residents evacuate such a disaster if their only method of egress were to be blocked? How would emergency vehicles (police, fire, paramedic) access Site 8 when the only ingress road is blocked (or when the freeways leading to the Santo Road exit are jammed)?
Traffic Comment 8: The Final EIS should address the specific public safety aspects of the Site 8 design approach, including specifically the requirement for and/or provision of alternate access methods (other than the single access road currently envisioned).
Traffic Issue 9: Access Road Infrastructure. The Draft EIS fails to provide any detail on the associated infrastructure intended for the new 2.5 mile access road that would connect Site 8A to the rest of San Diego (the extension of Santo Road, north of SR52).
Traffic Comment 9: The Final EIS should more fully explain plans for the access route that connects the Site to the northern terminus of Santo Road in terms of: sidewalks, bike routes/paths, a mid-point rest stop for pedestrians and bicycle riders, traffic pullout(s) or turnaround(s), and possible overlook(s). The Final EIS should address a possible a pedestrian-only bridge, separate from the current bridge for cars, that might be needed to provide said infrastructure.
Traffic Issue 10: School Buses for Middle and High School Students. The Draft EIS fails to address a school bus plan for the estimated 228 middle school students who will live in Site 8 and attend Tierrasanta/Murphy Canyon middle schools (either De Portola or Farb), or for the estimated 163 high school students who will live in Site 8 and attend Serra High School. A straightforward mitigation measure for traffic impact to the community of Tierrasanta/Murphy Canyon would be for these students to be brought to and from their schools via a military or city school bus.
Traffic Comment 10: The Final EIS should address plans for the provision of school buses between Site 8 and the three Tierrasanta/Murphy Canyon area schools expected to be used by military families.
Traffic Issue 11: What if the Elementary Schools are not Built? A “nightmare scenario” would result if the San Diego Unified School District (SDUSD) decided for some reason not to build the planned two elementary schools on Site 8 property, or if the building of these schools were to lag the completion of Site 8’s housing development by a year or more. This would mean all 1,172 of the projected K-5 students living in Site 8 would have to attend existing nearby SDUSD schools, and the Draft EIS clearly states the only schools Site 8 children would attend are those in Tierrasanta. Focusing in on the traffic-related ramifications alone, the Draft EIS assumes both schools are built as the first family takes up residence at Site 8, and it makes no prediction at all on the possible impact to Tierrasanta/Murphy Canyon streets should the schools not be built.
Traffic Comment 11: The Final EIS should amend the Traffic Analysis and report what actions will be taken: 1) to ensure the two schools are built on schedule, and 2) to mitigate the traffic impact should the two schools not be built on schedule.
Traffic Issue 12: Shuttle Buses for the Military Community. Similarly, the Draft EIS fails to include provision for some form of shuttle bus service that connects Site 8 to the facilities contained in MCAS Miramar (e.g., the Commissary and the Exchange).
The Draft EIS is also silent on whether any transit services (i.e., San Diego Transit, local bus service, etc.) will be provided to the site by the Metropolitan Transit Development Board (MTDB).
Traffic Comment 12: The Final EIS should address plans for the provision of commissary buses between Site 8 and the on-base facilities expected to be frequented by military families.
The Final EIS should address plans for public transit into the Site 8 area.
Traffic Issue 13: Funding of the Proposed Mitigations. A concern exists that while the Site 8 housing project itself might be funded in the Navy’s budget, the various mitigations and/or other infrastructure improvements specified in the Draft EIS might not be included in this budget.
Traffic Comment 13: The Final EIS should provide clarification on whether the Navy’s budget includes full funding for each and every mitigation measure listed in the Draft EIS. The Final EIS should explain whether the funding is intended to provide full mitigation prior to or concurrent with first occupation of Site 8 by military families (or, as occurred with Murphy Canyon, whether the funding to complete the infrastructure improvements will be strung out over several years). The Final EIS also should explain whether any additional required mitigations that arise from the EIS review process (that result from public comment) also will be fully funded.
Traffic Issue 14: Preference for MCAS Miramar Families at Site 8. In the perspective of a regional approach to traffic mitigation, it makes sense for a higher proportion of Site 8 residents to be posted to MCAS Miramar (higher than the 15% predicted in the Draft EIS). The concept of having military personnel living closer to their stations—across the region—would provide a simple yet straightforward approach to region-wide traffic mitigation: in aggregate, the traffic to and from military stations simply would have shorter commuting distances, and as such they would spend less time on the roads and impacting traffic. While this might worsen certain aspects of Site 8’s impact to Tierrasanta/Murphy Canyon (e.g., a higher proportion stationed at MCAS Miramar means the impact to that commuter route would be more significant than currently envisioned), the impact to other parts of Tierrasanta/Murphy Canyon probably would be lessened and the overall impact to transit conditions in greater San Diego also would improve (albeit marginally). Representatives of the Navy and USMC at the public forums held 22 and 24 July 2003 collectively concurred that locating more MCAS Miramar personnel at Site 8 made a great deal of sense, and they agreed to work this as a separate regional mitigation measure.
Implementing such a recommendation would seem to have minimal cost, and could take effect almost immediately on a regional basis in terms of how families are assigned to military housing.
Traffic Comment 14: The Final EIS should include language indicating the Navy’s adoption of the concept that a preference should be given to military families for appointment to housing that is geographically located nearer to where the families’ servicemen are posted.
Traffic Issue 15: Use of Confusing Terminology. “Site 8A” in the Draft EIS refers to the option that accesses Site 8 at Santo Road, while in Appendix C this is reversed and it refers to the option that accesses Site 8 via a new SR52 interchange. Similarly, “Site 8B” in the Draft EIS refers to the new SR52 interchange, while in Appendix C this is reversed and it refers to the Santo Road option.
Traffic Comment 15: The Final EIS should be revised to correct this obvious and confusing disconnect in terminology between the main document and its Appendix C.
Traffic Issue 16: Use of Out-of-Date Data & Possibly Missing Data. Several tables in Appendix C of the Draft EIS report average daily traffic (ADT) figures attributed to “SANDAG, San Diego Region Average Weekday Traffic Volumes 1994-1998” (Table 3.1 on page 16, Table 3.3 on page 21, Table 3.5 on page 26, etc.). Table 5.6 on page 55 of Appendix C references “SANDAG, 1994-1998 ADTs.” Other tables in Appendix C also show ADT values, so presumably these too are using the same SANDAG data circa 1994-98 (even though the reference is missing; e.g., Table 6-5 on page 65). The TCC has learned from CALTRANS that the referenced documents are in fact out of date, and the currently effective document for information on traffic levels is “1989 Thru [sic] 2002 Traffic Volumes on California Highways in District 11.” The information in this document frequently shows significantly increased traffic levels when compared to the older report. The 1989-2002 report lists the following as being the current traffic loading statistics:
ADT values along I-15 as of 2002: Aero Drive to Tierrasanta Blvd: 186,000 Tierrasanta Blvd to Clairemont Mesa Blvd: 173,000 Clairemont Mesa Blvd to SR52: 162,000 SR52 to I-15 (southbound): 162,000 I-15 (southbound) to SR163: 162,000 I-15 to Miramar Way: 272,000
ADT values along SR52 as of 2002: Convoy Street to SR163: 117,000 SR163 to Kearny Villa Road: 92,000 Kearny Villa Road to I-15: 70,000 I-15 to Santo Road: 85,000
Also, the following pages of Appendix C appear to be missing: 27, 72, 78, 119 and 120.
Traffic Comment 16: The Final EIS should explain why traffic data from 1994-1998 is deemed relevant to traffic predictions in 2004 and 2020. In preparing the Traffic Analysis and Appendix C, if this older data was updated for use in the Draft EIS, then the Final EIS should explain how the data was updated. Alternately, if the data was taken as is from the 1994-1998 SANDAG report, then the Final EIS should explain how data that is so old can be considered relevant to the predictions and recommendations of the EIS.
Also, the Final EIS should include an updated and repaginated Appendix C such that readers of the document can be sure there are no missing pages and no omitted information.
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